Real Estate Group in Gurgaon — Multiple POSH Complaints + Repeat Offender Situation
The Client: A premium real estate group operating 8 different residential projects across Delhi and Gurgaon, with around 300 employees across front desk, projects, office and management.
The Problem: The group's HR Head came to us after a difficult six months. Three blue-collar female employees filed three separate POSH complaints against the same site project manager, and one office receptionist filed a complaint against a regular guest.
The existing Internal Committee had tried to handle the first complaint on its own but made several mistakes:
- They didn't finish the inquiry within the 90-day deadline required by POSH law
- They didn't keep things confidential — leaked the case details with other staff
- They didn't have an External Member on the IC, which is required by law
On top of that, the project manager had filed a counter-complaint saying the process was unfair and biased against him. While this first complaint was still unresolved, a second complaint was filed against the same manager by another woman — making him a possible repeat offender, and the IC had no idea how to deal with that situation.
The third complaint was a completely different challenge — it was against a regular guest. The question was: can a guest even be treated as an accused person under the POSH Act?
The HR Head was under pressure and worried that one more mistake could lead to legal action against the company itself.
What We Did as a POSH Consultant:
- Reviewed all three complaints immediately, checked what steps had been taken so far, found the mistakes, and made a clear plan to fix them
- Joined the Internal Committee as External Member so the committee was legally compliant as per POSH law
- Restarted the inquiry for the first complaint the right way — sent a fresh notice to the accused person, interviewed witnesses
properly, made sure everything stayed confidential, and completed the inquiry within prescribed timeline by law
- Handled the repeat offender situation carefully — advised the IC and management on how to treat the second complaint separately while also looking at the pattern of behavior, which is a tricky area where most companies make mistakes
- Advised the IC on the guest complaint — explaining that under the POSH Act, the employer is responsible for taking action even when the accused person is an guest, and guided them on the right steps, including filing a police complaint if needed
- Drafted a completely new POSH policy designed specifically for the real estate industry — covering how female staff interacts with male employees at project site, rules for late-night shifts.
- Conducted POSH training for all 300 employees in 8 batches.
- Delivered detailed training to IC members on how to run an POSH inquiry
- Set up a confidential complaint channel in two languages (English and Hindi) available to all employees, including contract staff
- Prepared and filed the annual POSH compliance report with the District Officer.
- Started a monthly POSH check-in under the retainer — reviewing any new complaints, training new hires, and updating the IC team whenever members left the company
Final Result:All three complaints were resolved within the time limit set by POSH law. The first complaint was found to be genuine — the project manager was terminated after two separate complaints against him were both found to be true. The counter-complaint filed by the manager was reviewed and found to be false. The complaint against the guest was handled properly, including filing a police report. Finally, staff confidence in the complaint process increased significantly. In the following year, two more complaints were filed and resolved quickly and properly at the IC level. This is actually a good sign — it means employees now trust the system enough to use it. The real estate group started with nothing — no policy, no IC, no training. Today, they are fully POSH-compliant
